Other authors: Kirsty Morris

The House of Commons’ Joint Committee on Human Rights (the “Committee“) has launched a new inquiry to examine the UK’s current framework in relation to forced labour in international supply chains1. The Committee is seeking to establish if the current framework is effective in managing the risk of exposure to forced labour and whether it keeps up with international global developments. Submissions for evidence closed on 14 February 2025.

Legislative background

Modern slavery in international supply chains is predominantly governed in the UK by the Modern Slavery Act 2015 (the “MSA”). In October 2024, the House of Lords’ Modern Slavery Act Committee concluded in a report (the “Report“) that, despite the MSA being considered a world-leading piece of legislation when it was implemented, the UK has not kept up with global best practices. The Report recommended that the Government introduce mandatory modern slavery due diligence requirements.

 In its response to the Report2, the Government stated that it is planning to improve the modern slavery statement registry and that it supports voluntary due diligence approaches taken by UK businesses in line with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. The Government also stated that it is considering how it can strengthen penalties for non-compliance with the MSA.

Call for evidence

The Committee’s new inquiry presented an opportunity for stakeholders, including businesses, to share opinions on the effectiveness of the current UK framework in dealing with forced labour and to highlight the challenges they face in mitigating the risk of forced labour in their international supply chains. The Committee sought evidence on the following:

  1. Legislative Framework: The effectiveness of the MSA and other UK laws in preventing goods linked to forced labour from entering the UK market and whether this meets international compliance standards.
  2. Enforcement and Corporate Activity: The roles and powers of key public bodies in preventing forced labour-linked goods from entering the UK market.
  3. Consumer behaviour: The impact of forced labour exposure on consumer attitudes and corporate profits.
  4. Procurement: The relationship between procurement and the risk of exposure to forced labour.
  5. International approaches: Consider the approach of other jurisdictions, such as the EU and US.

International approaches to forced labour

International legislative approaches to forced labour are now more far reaching than under the MSA including notably the EU Forced Labour Regulation and the US (for example, under the Uyghur Forced Labor Prevention Act).

  • EU Forced Labour Regulation prohibits companies from “placing and making available” on the EU market, or exporting from the EU, products made using forced labour (see here for more information).
  • Uyghur Forced Labor Prevention Act prohibits the importation of goods produced wholly or in part in the Xinjiang Uyghur Autonomous Region of China, unless clear and convincing evidence proves they are not made with forced labour. It establishes a rebuttable presumption that all goods from this region are tainted by forced labour. This Act has also been implemented in Canada and Mexico pursuant to the United States-Mexico-Canada Agreement.

With regards to human rights due diligence obligations, a number of international laws impose more stringent requirements on businesses than those set out in the MSA. The Report cites the German Corporate Due Diligence in Supply Chains Act (see here and here for previous articles), the French Duty of Vigilance Law, the Norwegian Transparency Act and the EU’s Corporate Sustainability Due Diligence Directive (see here for changes presented by the “Omnibus” package) as going beyond the transparency requirements of section 54 of the MSA by introducing mandatory due diligence obligations.

Next steps

The Committee’s findings will provide an indication of the challenges faced by businesses in tackling forced labour in international supply chains. These are likely to inform the Government’s next steps in trying to implement its previous stated ambition of improving the UK’s framework in relation to forced labour.

  1. UK Parliament-Joint Committee on Human Rights, “New Inquiry: Forced Labour in UK Supply Chains Inquiry“, 21 January 2025, available at https://committees.parliament.uk/work/8812/forced-labour-in-uk-supply-chains/ ↩︎
  2. UK Home Office, “Government response to House of Lords Modern Slavery Act 2015 Committee report, ‘The Modern Slavery Act 2015: becoming world-leading again‘”, 16 December 2024, available at https://www.gov.uk/government/publications/modern-slavery-government-response-to-house-of-lords-committee-report/government-response-to-house-of-lords-modern-slavery-act-2015-committee-report-the-modern-slavery-act-2015-becoming-world-leading-again#response-to-recommendations-enforcement-of-the-modern-slavery-act ↩︎